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An Arizona hearing officer has recommended a four-year suspension with probation for two years if reinstated in a matter where the attorney had continued to practice after suspension for non-payment of bar dues. The attorney had continued to accept court appointments after the administrative suspension in at least 54 cases over approximatelt six months and was "[o]n information and belief" paid more than $55,000 for for appointed cases. The attorney had failed to cooperate in the ensuing disciplinary process.

The hearing officer concluded:

...the challenge is to decide whether the [attorney] can salvage her legal career. To recommend disbarment on this record is to conclude that the [attorney] is beyond the point of rehabilitation. Certainly the length of time in which [the attorney] knowingly represented clients in court while on suspension leads to the conclusion that [the attorney] will not follow the rules for professional conduct. It seems ludicrous that a person who is being paid $55,000 over a six-month period... cannot pay annual bar dues. The hearing oficer suspects that something else is involved in [the attorney's] conduct...